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Navigating the New Era of Immigration Enforcement

Client Alert

What Employers Need to Know in 2025

Introduction

The landscape of U.S. business immigration is undergoing a seismic shift in 2025. For multinational corporations, the stakes have never been higher: federal agencies are intensifying scrutiny, increasing site visits, and rolling out new compliance requirements. These changes are not just bureaucratic hurdles—they directly impact your ability to hire and retain global talent, maintain legal compliance, and avoid costly disruptions.

This post will break down the latest enforcement trends, explain what they mean for your business, and provide actionable strategies to stay ahead.

1. The Rise of Immigration Audits and Site Visits

What’s Changing? Federal agencies, including U.S. Citizenship and Immigration Services (USCIS) and Immigration and Customs Enforcement (ICE), are conducting more frequent and detailed audits. Site visits—once relatively rare—are now a routine part of the compliance landscape. These inspections target everything from H-1B and L-1 visa holders to PERM labor certifications and I-9 records.

Why It Matters for Multinational Employers

  • Increased Scrutiny: Audits are no longer limited to high-risk industries or random checks. Employers in all sectors, especially those with large foreign workforces, should expect unannounced visits.
  • Broader Scope: Inspectors are reviewing not just visa documentation, but also payroll records, job descriptions, and even workplace conditions to ensure compliance with labor laws.
  • Higher Stakes: Non-compliance can result in fines, visa revocations, or even criminal charges for willful violations.

Real-World Impact A recent report from the Bush Center highlights that immigration arrests have more than doubled in 38 states, with ICE conducting an average of 666 arrests per day nationwide—up from fewer than 300 daily in 2024. While these numbers include all immigration enforcement, they underscore the heightened environment for all employers.

Read the complete article to find out more about these policies, strategies, and consequences for employees at www.removal-defense.com. Get a deeper understanding of:

2. The Role of the New Office of Immigration Policy

3. Actionable Strategies for Multinational Corporations

4. The Cost of Non-Compliance: Penalties and Consequences for Employers

5. The Road Ahead: Staying Proactive in a Shifting Landscape

For guidance on these immigration issues, please contact BMD Member Robert Ratliff at raratliff@bmdllc.com. With over 25 years of trial experience in criminal defense and immigration law, Robert’s unique insights as a former Immigration Judge allow him to offer strategic guidance for clients facing complex immigration challenges.


USCIS Policy Change Impacting Work Authorization: Advisory for Employers and Human Resources

USCIS has issued a policy memorandum pausing immigration benefit processing for individuals from 19 high-risk countries and requiring a re-review of certain previously approved cases. This change may affect work authorization, employment verification, and workforce stability. Employers and HR teams should review impacted employees and update compliance procedures.

CMS Releases CY 2026 Medicare Physician Fee Schedule Final Rule with Key Payment and Telehealth Updates

CMS issued the CY 2026 Medicare Physician Fee Schedule Final Rule on October 31, 2025, with changes effective January 1, 2026. The Final Rule includes increases to the conversion factor, a new efficiency adjustment, updates to practice expense methodology, permanent telehealth policy changes, revised payment for skin substitutes, expanded rules for Part B drugs and biologicals, enhanced policies for Rural Health Clinics and Federally Qualified Health Centers, and new care management and behavioral health services.

Ohio Department of Medicaid Updates: Key Changes to Physician Reimbursement Rates in Early Parenthood

The Ohio Department of Medicaid has proposed amending Ohio Administrative Code Rule related to covered Medicaid reimbursements for physicians. Beginning on January 1, 2026, they are proposing an increase to rates for prenatal care, childbirth, and infant care and provider visits.

Name, Image, and Likeness Agreements in Healthcare

For example, some healthcare providers have begun to utilize "Name, Image, and Likeness" agreements to promote the brand they have created through their healthcare practice.  We have seen the most healthcare NIL activity with longevity and wellness providers, as well as orthopedics.

Compounding GLP-1 Drugs - Recent Updates

Recent guidance from the Ohio Board of Pharmacy (“BOP”) indicates that providers should generally use the FDA approved GLP-1 drug, rather than a non-FDA approved compounded version of the medication. Importantly, if a GLP-1 drug is commercially available, it cannot be copied through compounding. Currently, compounded copies of Tirzepatide and Semaglutide are not permitted.